REACH SVHC compliance is not a one-time task

REACH SVHC compliance is one of the most important chemical compliance requirements for companies placing products on the EU market. It affects not only chemical suppliers, but also companies selling articles, components, spare parts, equipment, consumer goods, industrial products, electronics, machinery, automotive parts, packaging, textiles, and other complex products.

The challenge is that the REACH SVHC Candidate List continues to change. Every update can create new obligations for supplier data collection, article-level screening, customer communication, consumer responses, SCIP notifications, Safety Data Sheet reviews, and compliance documentation.

The latest official ECHA update was published on 4 February 2026, when two substances were added to the Candidate List: n-hexane and 4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts, also known as Bisphenol AF and salts. ECHA stated that the Candidate List now contains 253 entries.

For companies, the key question is no longer only: “Do we have a REACH declaration?” The more important question is: “Can we prove, at article and component level, that our product data is accurate, current, traceable, and ready for customer, authority, or SCIP-related requirements?”

REACH SVHC vs Annex XIV vs Annex XVII: what is the difference?

Many companies confuse the REACH Candidate List with the Authorisation List and the Restriction List. They are connected, but they are not the same.

ECHA explains that companies wanting to continue using a substance included in Annex XIV after the sunset date need to apply before the latest application date and obtain a positive authorisation decision. ECHA also explains that restricted substances under REACH are substances for which manufacture, placing on the market, or use is limited or banned in the EU.

For business teams, the practical takeaway is simple: the Candidate List is often the first warning signal, but companies should also monitor whether relevant substances move toward authorisation or restriction.

What should companies ask suppliers for?

Supplier data is one of the biggest pain points in REACH SVHC compliance. A useful supplier request should be specific, current, and linked to the correct part, material, or product.

Companies should ask suppliers for:

• Updated REACH SVHC declaration based on the latest Candidate List
• Supplier name, contact person, and declaration date
• Product name, part number, material name, and revision/version
• Confirmation of whether any Candidate List SVHC is present above 0.1% w/w
• Substance name, CAS number, EC number, and concentration range where relevant
• Location of the SVHC in the article or component
• Safe-use information if an SVHC is present above threshold
• Full Material Declaration, if available
• Safety Data Sheet, where relevant for substances or mixtures
• Test reports, specifications, or supporting evidence where appropriate
• Confirmation that the supplier will update the declaration when the Candidate List changes

The goal is to move from generic supplier statements to controlled, product-specific evidence.

What documents should companies keep as evidence?

REACH SVHC compliance should be supported by traceable records. Under REACH Article 36, manufacturers, importers, downstream users, and distributors must keep available the information they need to carry out their duties for at least 10 years after last manufacture, import, supply, or use of the substance or mixture.

A strong REACH SVHC compliance file may include:

This evidence is important for audits, customer requests, authority inspections, market surveillance, tenders, and internal governance.

What is the REACH SVHC Candidate List?

The REACH SVHC Candidate List is the list of Substances of Very High Concern identified under the EU REACH Regulation. ECHA explains that substances with serious and often irreversible effects on human health or the environment may be identified as SVHCs and added to the Candidate List for possible future inclusion in the Authorisation List.

A substance may be identified as an SVHC because it is, for example:

• Carcinogenic, mutagenic, or toxic to reproduction
• Persistent, bioaccumulative, and toxic
• Very persistent and very bioaccumulative
• Of equivalent concern, such as certain endocrine-disrupting substances or substances with serious human-health or environmental concerns

Adding a substance to the Candidate List does not automatically mean that the substance is banned in every product. However, it can create immediate legal obligations for companies when the substance is present in articles, substances, or mixtures under certain conditions. ECHA states that obligations can apply from the date of inclusion and may affect substances on their own, substances in mixtures, and substances in articles.

Latest REACH SVHC List update in 2026

On 4 February 2026, ECHA added two substances to the REACH Candidate List, bringing the list to 253 entries.

This update matters because the newly added substances may appear in supply chains connected to formulations, coatings, polymer processing, cleaning agents, process regulators, cross-linking agents, and complex products that include sourced materials or components.

Do companies need to take action after the February 2026 update?

Companies should review their REACH SVHC compliance status after every Candidate List update. Action may be needed if the company manufactures, imports, distributes, or supplies products in the EU or EEA and any product, component, material, coating, adhesive, sealant, polymer, elastomer, textile, formulation, or sub-assembly may contain a newly added Candidate List substance.

A practical impact review should answer these questions:

1- Do any products contain n-hexane or Bisphenol AF and salts?

2- Are these substances present in articles above 0.1% weight by weight?

3- Are supplier declarations updated after the February 2026 Candidate List change?

4- Do any Article 33 customer communication duties apply?

5- Do any consumer right-to-know response obligations apply?

6- Is Article 7(2) notification to ECHA required?

7- Is a SCIP notification or SCIP update required?

8- Are Safety Data Sheets affected for substances or mixtures?

9- Is the compliance evidence traceable, current, and linked to the correct product version?

If the answer is unclear, the company has a compliance data gap that should be investigated.

Why article-level screening matters

For companies selling complex products, REACH SVHC compliance must be managed at article and component level. The Court of Justice of the European Union clarified in Case C-106/14 that, for complex products, the 0.1% threshold is assessed by reference to each component that qualifies as an article, not only the final assembled product.

This means a company cannot rely only on a finished-product-level statement. A small component, coating, connector, cable, seal, textile part, plastic housing, electronic part, or spare part may trigger obligations if it contains a Candidate List SVHC above the threshold.

For compliance teams, this creates a clear practical requirement: product data must be structured by article, component, material, supplier, and product version.

Core REACH SVHC obligations companies must understand

1. Article 33 communication to professional recipients

Under REACH Article 33, EU and EEA suppliers of articles containing a Candidate List SVHC above 0.1% weight by weight must provide sufficient information to allow safe use of the article. At minimum, the communication must include the name of the SVHC. ECHA confirms that this obligation applies to suppliers of articles when Candidate List substances are present above the threshold.

For B2B supply chains, this means customers need accurate and product-specific information. A general statement such as “REACH compliant” may not be enough if an SVHC is present above 0.1% w/w in an article.

2. Consumer right-to-know response within 45 days

If a consumer asks whether an article contains a Candidate List SVHC above 0.1% w/w, the supplier must provide sufficient safe-use information free of charge within 45 days.

This is not only a legal issue. It is also a workflow issue. Companies need a clear process for receiving the request, checking the product data, approving the response, and keeping a record of what was communicated.

3. Article 7(2) notification to ECHA

EU and EEA producers or importers may need to notify ECHA when a Candidate List substance is present in articles above 0.1% w/w and the total amount of that substance exceeds one tonne per producer or importer per year. ECHA states that notification is required no later than six months after the substance is added to the Candidate List, unless an exemption applies.

To assess this correctly, companies need reliable data on substance identity, article-level concentration, affected articles, annual tonnage, use conditions, and any exemption reasoning.

4. SCIP notification for articles on the EU market

SCIP is ECHA’s database for information on Substances of Concern In articles as such or in complex objects. ECHA states that companies supplying articles containing Candidate List SVHCs above 0.1% w/w on the EU market have had to submit information to ECHA from 5 January 2021.

SCIP is closely linked to REACH SVHC data, but it is a separate obligation under the Waste Framework Directive. In practice, the same product, component, material, and substance data used for REACH SVHC screening may also be needed for SCIP submissions.

5. Safety Data Sheet review for substances and mixtures

When a substance is added to the Candidate List, suppliers of substances and mixtures may need to review Safety Data Sheets and communication duties. ECHA notes that Candidate List inclusion may create obligations under Article 31, which concerns Safety Data Sheets.

This is especially relevant for companies working with chemicals, formulations, coatings, adhesives, cleaning agents, and industrial mixtures.

What if suppliers do not respond?

Supplier non-response is common, but it should not stop the compliance process. Companies should use a documented escalation and risk-based approach.

A practical process may include:

1- Send a structured supplier request with a clear deadline.

2- Follow up with reminders and escalation to procurement or supplier management.

3- Prioritise high-risk materials, suppliers, and product categories.

4- Use existing evidence such as SDSs, specifications, previous declarations, or material data where appropriate.

5- Consider testing for high-risk or uncertain materials.

6- Document all assumptions, gaps, and follow-up actions.

7- Decide whether the product can be released, restricted, blocked, or subject to further investigation.

The key is not to leave supplier gaps hidden in emails or spreadsheets. Missing data should be visible, tracked, assigned, and resolved.

When should companies use testing?

Testing can be useful, but it should be used carefully. It can help verify high-risk materials, confirm supplier information, investigate suspected SVHC presence, or support customer and audit questions.

However, testing does not always replace supplier data. A complex product may contain many components, materials, coatings, versions, and supplier variations. One test may not cover all product configurations or all future supplier changes.

Testing is most useful when:

• Supplier data is missing, outdated, or unreliable
• A material is known to have higher SVHC risk
• A product is being prepared for a major customer or market access requirement
• There is a compliance dispute or audit request
• The company needs additional evidence to support a risk-based decision

The best approach is usually a combination of supplier declarations, material data, targeted testing, and documented compliance logic.

Common REACH SVHC compliance mistakes

Mistake 1: Treating REACH declarations as permanent

The Candidate List changes over time. A declaration that was acceptable before the February 2026 update may need to be reviewed after n-hexane and Bisphenol AF and salts were added.

Mistake 2: Screening only the finished product

The 0.1% threshold must be assessed at article or component level for complex products. Screening only the finished product may miss components that trigger communication or notification duties.

Mistake 3: Relying on generic supplier statements

A supplier statement should be linked to the correct product, part number, material, version, date, and Candidate List status. Generic statements are weak evidence during audits or customer reviews.

Mistake 4: Missing SCIP updates

If a product contains a Candidate List SVHC above 0.1% w/w and is placed on the EU market, SCIP obligations may apply. ECHA confirms that companies supplying such articles on the EU market have had to submit information to SCIP since 5 January 2021.

Mistake 5: No consumer request workflow

The 45-day consumer response obligation requires a controlled process. Without assigned responsibility, approved templates, and accessible product data, companies may miss the deadline.

Mistake 6: No evidence trail

Compliance is not only about having the final answer. Companies also need to show how they reached the answer, what data was used, who approved it, and when it was updated.

Practical REACH SVHC compliance checklist for 2026

How often should companies review REACH SVHC compliance?

Companies should review REACH SVHC compliance:

• After every Candidate List update
• Before placing a new product on the EU market
• When suppliers, materials, formulations, or components change
• When a customer requests updated compliance evidence
• Before SCIP submission or SCIP updates
• Before tenders, audits, or market surveillance checks
• During annual product compliance reviews

For companies with large product portfolios, this can become difficult to manage manually. A single Candidate List update can require checking many products, contacting many suppliers, updating declarations, assessing Article 33 duties, and reviewing SCIP data.

How ComplyMarket product compliance software helps

REACH SVHC compliance is a product data and supplier evidence challenge. Regulations define the obligations, but companies meet those obligations through reliable data, structured workflows, traceable decisions, and controlled communication.

ComplyMarket helps companies centralize material and product compliance, build digital product passports, and streamline ESG and compliance reporting with less manual work and faster market access.

For REACH SVHC List compliance, ComplyMarket supports companies with a structured process for Candidate List screening, Article 33 communication, ECHA notification readiness, supplier data collection, BOM-based screening, and long-term evidence retention.

1. Automate SVHC screening across products and BOMs

ComplyMarket helps companies screen multi-level BOMs and complex products at component and article level. This supports the “once an article, always an article” approach and reduces the risk of missing SVHCs in sub-components.

2. Manage supplier declarations with traceability

Instead of relying on scattered emails and spreadsheets, companies can collect, review, approve, and update supplier declarations in a controlled workflow. This helps compliance teams identify missing, outdated, or incomplete supplier data.

3. Create consistent Article 33 outputs

When an SVHC is present above threshold, companies need consistent safe-use information for professional recipients and consumers. ComplyMarket supports organized data management for Article 33 communication and consumer inquiry workflows.

4. Maintain Article 7(2) decision logs

Article 7(2) notification depends on concentration, tonnage, article scope, and exemptions. ComplyMarket helps companies maintain structured decision logs and notification-ready datasets where needed.

5. Support SCIP readiness and data reuse

SCIP requires structured article, complex object, material, substance, and safe-use information. ComplyMarket helps companies reuse REACH SVHC data for SCIP-related workflows where applicable.

6. Keep compliance evidence audit-ready

ComplyMarket helps companies maintain version-controlled, audit-friendly evidence, including supplier declarations, material data, product screening results, Article 33 records, decision logs, and supporting documentation.

Why software matters for REACH SVHC compliance in 2026

Manual compliance processes can work for a small product portfolio, but they become risky when companies manage many SKUs, suppliers, components, and market requirements.

The main risks are:

• Outdated supplier declarations
• Missing article-level data
• Unclear product version history
• No clear owner for Candidate List updates
• Weak Article 33 communication records
• Uncontrolled consumer request processes
• SCIP data gaps
• Poor audit evidence

A structured product compliance platform helps turn REACH SVHC compliance from a reactive documentation task into a repeatable, scalable, and evidence-based business process.

FAQ: REACH SVHC List Compliance

What is the latest REACH SVHC List update?

The latest verified ECHA update was published on 4 February 2026. ECHA added n-hexane and Bisphenol AF and salts, bringing the Candidate List to 253 entries.

Does SVHC listing mean the substance is banned?

No. Candidate List inclusion does not automatically ban a substance in all uses. However, it can trigger legal duties such as Article 33 communication, Article 7(2) notification, SDS review, and SCIP-related obligations depending on the product and use.

What is the REACH SVHC threshold for articles?

The key threshold is 0.1% weight by weight. For complex products, this threshold must be assessed at article or component level, not only across the finished product.

When is Article 33 communication required?

Article 33 communication is required when an article contains a Candidate List SVHC above 0.1% w/w. Suppliers must provide sufficient safe-use information to professional recipients and, upon consumer request, provide the information free of charge within 45 days.

When is Article 7(2) notification required?

Article 7(2) notification may be required when a Candidate List substance is present in articles above 0.1% w/w and the total amount exceeds one tonne per producer or importer per year. ECHA states that notification is required no later than six months after the substance is added to the Candidate List, unless an exemption applies.

Is SCIP the same as REACH Article 33?

No. SCIP is a separate database obligation under the Waste Framework Directive, but it is closely linked to REACH SVHC data. ECHA states that companies supplying articles containing Candidate List SVHCs above 0.1% w/w on the EU market have had to submit information to SCIP from 5 January 2021.

What should companies do if supplier data is missing?

Companies should document the gap, follow up with suppliers, escalate internally where needed, use available supporting evidence, consider targeted testing for higher-risk materials, and keep a clear record of decisions and assumptions.

How can ComplyMarket help with REACH SVHC compliance?

ComplyMarket helps companies manage REACH SVHC compliance through supplier data collection, BOM-based SVHC screening, article-level assessment, Article 33 communication support, Article 7(2) decision logs, SCIP readiness, and audit-ready evidence management.